to the extent of the Partnership's current or accumulated earnings and profits, (ii) a return of basis to the extent of each Partner's basis in its Partnership Interest and (iii) gain to the extent any remaining distributions exceeded the Partner's basis in its Partnership Interest. Overall, treatment of the Partne

igations, the Service might take the position that all or a part of the interest paid by such Limited Partner in connection with the purchase of his Partnership Interest should be viewed as incurred to enable such Limited Partner to continue carrying tax-exempt obligations, and that such Limited Partner should not b